Assess whether a redlining pattern exists after controls (57b5fb)

Situation

The desk packet is underwriting exception log by branch after a CRA PE that called the assessment area too narrow. Fair-lending officer in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from underwriting exception log by branch after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in underwriting exception log by branch — reopen intake, do not close a redlining pattern exists.
• Two facts in underwriting exception log by branch after a CRA PE that called the assessment area too narrow conflict for fair-lending officer; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a CRA PE that called the assessment area too narrow and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.